In Jennings v. Zoning Board of Adjustment of City of Pittsburgh, (PA Commonwlth. Ct., July 28, 2011), a Pennsylvania appellate court upheld a finding by Pittsburgh's Zoning Board of Adjustment that proposed use of a property for a contemplative community in a communal group living arrangement should be classified as a "multi-suite residential" use and not use for "religious assembly." The only religious component would be communal prayer sessions for the residents held within the house for approximately 15-20 minutes, twice each day, and possibly weekly spiritual training by the program manager. There would be no designated area for prayer and no public worship on the premises.

